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of Income accrued in India - Benefit of consistency on the basis of orders for earlier assessment years - There was complete silence on this issue by the assessing officer and in our view , there is no purpose of perpetuating the illegality/irregularity either by the assessing officer or by the tribunal. There cannot be consistency of decisions but when there is no decision by the revenue for the earlier years, then there cannot be consistency for no-decisions. - No reason to grant the benefit of consistency to the assessee. - AT
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